Limitation finding on extended period and absence of suppression sustained; Special Leave Petition dismissed.

The Tribunal's limitation finding was left undisturbed because the show cause notice was held to be beyond the normal period and the extended period was unavailable in the absence of suppression. That limitation conclusion was not challenged before the HC, and the SC found no reason to entertain the Special Leave Petition, which was dismissed.

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Outcome: Special Leave Petition dismissed. The order notes that the limitation finding recorded by the Tribunal, including that the show cause notice was beyond the normal period and that the extended period was unavailable for want of suppression, had not been questioned before the High Court and no reason was found to entertain the petition.

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